In order to abide by BSA/AML compliance regulations, a reliable Customer Identification Program (CIP) is a must. With the development of technology, CIP programs have become increasingly tighter to protect against things like identity theft and organized crime. Security efforts were particularly advanced after 9/11. Due to this, in 2003, CIP was added as a requirement to the Bank Secrecy Act.
In simple terms, a CIP program protects the security of customers who are banking in a financial institution. The CIP prioritizes customers who open new accounts, having systems and processes in place that determine if the customer is indeed who they say they are. This does not just apply to a single individual, but can also include corporations, businesses, trusts and estates. So if you don’t comply with Customer Identification Program rules, there could be serious repercussions from the government, such as the bank operations being entirely shut down.
In order to prevent this, ensure your Customer Identification Program incorporates these three elements:
Well Written Program and Procedures
As part of the changes to the Bank Secrecy Act, each and every financial institution must have a written Customer Identification Program. However, making sure that your program is understood and easily digestible for all parties is key to ensuring every rule is abided by and avoiding any risks. In the CIP document, it’s crucial to include depth and detail concerning every situation you might come across to verify the true identity of a new enrolling customer. At the surface level, the requirements of a CIP program include four pieces of identification required from the customer: their name, address, date of birth, and ID Number.
However, as stated above, there should be methods in place for varying situations as well, including:
Verification through documentation
If an individual cannot present their ID
If you aren’t familiar with the type of ID a customer presents
If the customer does not come in person
When a customer can use an account while the bank attempts to verify a customer’s ID
When someone should NOT open an account
Why the financial institution would have to close an account due to a filed customer ID
While it’s essential to have a clearly articulated Customer Identification Program, it is equally important to ensure your workers are trained to carry it out.
Your Customer Identification Program is only as strong as the people who are enforcing the rules and working to comply with them on a daily basis. The importance of employing a quality BSA Officer to hold your team accountable and teach them the importance of following the CIP Program is essential.
This person should:
Have a deep knowledge of AML Compliance
Know if any updates or changes need to be made to your CIP program regularly
Know how to track and monitor high-risk accounts and customers and be able to pinpoint new onboarded customers who look suspicious
Immediately know to notify authorities of suspicious activity such as cash purchases of negotiable instruments or transactions exceeding $10,000
In addition, clear expectations must be laid out for employees through training. This should include:
Record-keeping procedures: Walk them through what is required to keep on a customer’s record. This should also include what is required to keep on file after they are no longer a customer. You might be legally required to keep certain files and discard others, so it’s important that your team knows which is which.
Ensuring they know how to verify an ID and other documentation: Regularly test out your teams’ knowledge of what is and is not an acceptable form of ID.
Note that regular training sessions, even if they are scheduled-out refresher sessions, can be a surefire way to ensure your Customer Identification Program is effective and impactful. Given the large digital presence in the world we live in, it’s critical that you guarantee the success of your CIP not just in-person, but also over the web.
Remote and In-Person Verification System
Fraudsters are only continuing to improve their craft, so having systems in place for an in-person verification as well as online is absolutely necessary. Unfortunately, we can only rely on the human eye to an extent, or facial recognition software in remote cases, which is why it’s imperative to count on the aid of technology in order to immediately and accurately determine whether the customer’s ID is the real deal.
Investing in a great in house ID Verification System is critical to covering your bases and safeguarding your financial institution. Nowadays, it’s easy to open up a bank account online, which means the verification process is now often completed online.
When selecting your ID Verification System for in-person and online, make sure you consider the following:
The customer experience: Studies show that customer satisfaction is the largest competitive advantage for banks
Efficiency: Immediate results of whether their ID has been verified or not keeps the customer happy and engaged, especially online
Accuracy: ensuring accuracy from the get-go prevents extra hassle not only for the customer, but also for your team and your business
Facial Recognition: Some ID authentication systems offer facial recognition for online applications to ensure that the cardholder is still in control before authorizing the account.
While you should prioritize customer experience and efficiency, accuracy of the system is a complete must— you can’t afford to have any slip-ups. This is why you should carefully consider the available identification verification systems to make sure you choose the right technology with no risk of error.
Ensure Total Accuracy with Intellicheck
With a high-functioning and multidimensional operation like banking, it is vital that you are able to provide an accurate Customer Identification Program. Technological ID checking services that encompass everything from document authentication to facial recognition can make a huge impact on your CIP program. That’s where Intellicheck comes in, making your authentication process seamless and easy.
With a user-friendly interface that can be downloaded right onto a smartphone, Intellicheck can be used with ease by your trained team both in-person and online. Intellicheck, with its efficiency and guaranteed accuracy, will leave no room for complaint and little room for error, providing the security your bank, your employees, and your customers need.